Vishal Agrawal & Anr vs Chattisgarh State Electricity Board ...

The Supreme Court addressed the applicability of the amended Section 151 of the Electricity Act, 2003, which allows courts to take cognizance of offences based on police reports under Section 173 of the Code of Civil Procedure. The Court held that the amendment applies to pending complaints, thereby validating the complaint made by the Chhattisgarh State Electricity Board against the appellants for electricity theft. The Court reversed the High Court's decision that had previously discharged the appellants, affirming the validity of the complaint under the amended provisions.